After a year of uncertainty, the dust has finally settled around the Omnibus reforms. We now have certainty on CSRD and CSDDD scoping as Omnibus I came into force on March 18. The new ESRS are the last piece of outstanding rulemaking. Once those are in place, there should be no more surprises. Now it’s time for companies to reassess, refocus, and resume data gathering and reporting. A recent memo from Crowe examines how internal audit teams can refocus their assurance efforts and offers these practical tips:
- “Scope and perimeter testing: Confirm CSRD/CSDDD thresholds and document conclusions for each entity; assess residual obligations from customers, lenders or parent entities.
- Governance and accountability: Test RACI, board oversight, executive ownership, control owners for key metrics, and evidence of competence and resourcing for sustainability actions.
- Double materiality as a controlled process: Treat the DMA as an end‑to‑end workflow (inputs → criteria → thresholds → decisions → outputs); require documented thresholds, assumptions and data sources; check connectivity to financial reporting and challenge boilerplate rationales.
- Data and measurement integrity: Validate the ESG data architecture, definitions, calculation logic, reconciliations, control design, evidence retention and management review, aiming for external assurance readiness.
- Due diligence under the amended CSDDD (where in scope): Evaluate chain‑of‑activities risk mapping, prioritisation logic, grievance mechanisms, monitoring cadence (≥ five years plus triggers) and documentation sufficiency to withstand national enforcement.”
For those still in the scope of CSRD and CSDDD the hard work of sustainability compliance and reporting continues.
Our members can learn more about sustainability reporting here.
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